Effective as of 1 August 2020
Thanks for choosing Doggies in Town!
At Doggies in Town, we want to give you the best possible experience to ensure that you enjoy our service. To do this we need to understand your habits using our service, so we can deliver an exceptional and personalized service specifically for you. Your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data – as well as outline the controls and choices you have around when and how you choose to share your personal data.
Our Services are owned and operated by Doggies in Town S.L.. By visiting our websites and related applications, whether on a computer, phone, tablet, or similar device (these are all referred to as a “Device”), you are accepting the practices described below.
This Policy sets out the essential details relating to your personal data relationship with Doggies in Town. The Policy applies to all Doggies in Town services and any associated services (referred to as the ‘Doggies in Town Service’). The terms governing your use of the Doggies in Town Service are defined in our Terms and Conditions of Use (the “Terms and Conditions of Use”).
From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.
The aim of this Policy is to:
- Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
- Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Doggies in Town Service; and
- Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see Section 16 ‘How to contact us’ below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Doggies in Town Service.
The General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:
- Right of access – the right to be informed of, and request access to, the personal data we process about you;
- Right to rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to erasure – the right to request that we delete your personal data;
- Right to restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to object –
- the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
- the right to object to your personal data being processed for direct marketing purposes;
- Right to data portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
- Right not to be subject to automated decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
In order to enable you to learn more about these rights, exercise these rights with ease, and record your preferences in relation to how Doggies in Town uses your personal data, we provide the following resources:
- Privacy Settings (accessed via your account page) – allows you to exercise choices about the processing of certain personal data.
- FAQ – provides a convenient central location where you can find more information about how Doggies in Town uses your personal data, your rights in relation to your personal data, how to exercise those rights and further guidance about data protection questions.
If you have any questions about your privacy, your rights, or how to exercise them, please contact our Data Protection Officer by sending an email to firstname.lastname@example.org. If you have concerns around our processing of your personal data, we hope you will continue to work with us to resolve them. However, you can also contact and have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos) or your local Data Protection Authority.
We have set out in the tables below the categories of personal data we collect and use about you and how we collect it:
The table below describes personal data collected when you sign up for the Doggies in Town Service:
Categories of personal data
Description of category
This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Doggies in Town Service. Depending on the type of Doggies in Town Service plan you sign up for, this may include your first name, last name, company name, email address, birth date, gender, interests, company address, company category and company subcategories.
Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with additional personal data in order to make your account more personalized.
The exact personal data we will collect depends on the type of Doggies in Town Service plan you sign up for, how you create an account, and whether you use third party services (such as Google) to sign up and use the Doggies in Town Service. If you use a third party service to create an account, we will receive personal data via that third party service but only when you have consented to that third party service sharing your personal data with us.
The table below describes personal data collected through your use of the Doggies in Town Service:
Categories of personal data
Description of category
This is the personal data that is collected about you when you’re accessing and/or using the Doggies in Town Service, including:
The table below describes personal data that you choose to give us that enables us to provide you with additional features/functionality
Categories of personal data
Description of category
Payment and Purchase Data
We may collect certain personal data if you sign up for a Trial or purchase any of our Paid Subscriptions (as defined in the Terms and Conditions of Use) or make other purchases through the Doggies in Town Service. The exact personal data collected will vary depending on the payment method (e.g. direct via your mobile phone carrier) but will include information such as:
Contests, Surveys and Sweepstakes Data
When you complete any forms, respond to a survey or questionnaire, or participate in a contest, we collect the personal data you provide.
The table below describes personal data collected from third party sources
We collect personal data about you from various third parties. These third party sources vary over time and include the following:
Categories of personal data
Description of category
If you register for or log into our services using third party credentials (e.g. Google), we will import your information from such third party to help create your account with us.
Technical service partners
We work with technical service partners that provide us with certain data, such as mapping IP addresses to precise and non-precise location data, to enable us to provide the Doggies in Town Service, content, and features.
If you choose to pay for a service or feature by invoice, we may receive data from our payment partners to enable us to send you invoices, process your payment and provide you with what you’ve purchased.
Advertisers and other advertising partners
We may obtain certain data about you, such as cookie id, mobile device id, or email address, and inferences about your interests and preferences from certain advertisers and advertising partners that allow us to deliver more relevant ads and measure their effectiveness.
When you use or interact with the Doggies in Town Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 4 ‘Personal data we collect from you’ used for these purposes:
Description of why Doggies in Town processes your personal data (‘processing purpose’)
Legal Basis for the processing purpose
Categories of personal data used by Doggies in Town for the processing purpose
To provide and personalize the Doggies in Town Service.
To understand, diagnose, troubleshoot, and fix issues with the Doggies in Town Service.
To evaluate and develop new features, technologies, and improvements to the Doggies in Town Service.
For marketing, promotion, and advertising purposes.
To comply with legal obligations and law enforcement requests.
To fulfill contractual obligations with third parties, for example licensing agreements and to take appropriate action with respect to reports of intellectual property infringement and inappropriate content.
To establish, exercise, or defend legal claims.
To conduct business planning, reporting, and forecasting.
To process your payment.
To detect fraud, including fraudulent payments and fraudulent use of the Doggies in Town Service.
To conduct research, contests, surveys, and sweepstakes.
If you require further information about the balancing test that Doggies in Town has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see Section 16 ‘How to contact us’ for further details on how to contact us.
We have set out the categories of recipients of the personal data collected or generated through your use of the Doggies in Town Service.
Publicly available information
The following personal data will always be publicly available on the Doggies in Town Service: your first name, profile picture and your given business reviews.
Personal data you may choose to share
The following personal data will only be shared with the categories of recipients outlined in the table below if:
- you choose to make use of a specific Doggies in Town Service feature where sharing of particular personal data is required for the proper use of the Doggies in Town Service feature; or
- you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Doggies in Town Service or authorizing Doggies in Town through a presented consent mechanism.
Categories of Recipients
Reason for sharing
Third party applications and devices you connect to your Doggies in Town Account
If you connect your Doggies in Town account to a third party application and/or device(s), such as, social media, audio, television, or automotive platforms and services, Doggies in Town shares technical data with the operator of that third party application and/or device in order to connect your Doggies in Town account. With respect to certain third parties which may request or require that we share your information with them, your permission will be requested before we provide your information to such third parties.
When you register for a Doggies in Town Account, we will ask you to share your first name and profile photo. This will be publicly displayed on the business profile of the company you reviewed along with any comments and photos you post.
Businesses & partners
You may choose to share personal data (for example, your email address) with businesses or other partners who may want to directly send you news or promotional offers. You will always have the option to change your mind and withdraw your consent at any time.
Learn more about how to manage notifications, your publicly available information, and what you share with others in Section 3 ‘Your rights and your preferences: Giving you choice and control’ of this Policy.
Information we may share:
Categories of Recipients
Reason for sharing
We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we’ve hired to provide customer service support, operate the technical infrastructure that we need to provide the Doggies in Town Service, assist in protecting and securing our systems and services, and help market Doggies in Town’s own products and services as well as partner products, services, events, and co-branded promotions in which Doggies in Town is involved.
We will share your personal data with our payment processors as necessary to enable them to process your payments, and for anti-fraud purposes.
We work with advertising partners to enable us to customize the advertising content you may receive on the Doggies in Town Service. These partners help us deliver more relevant ads and promotional messages to you, which may include interest based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising on the Doggies in Town Service. We and our advertising partners may process certain personal data to help Doggies in Town understand your interests or preferences so that we can deliver advertisements that are more relevant to you.
Doggies in Town partners
Depending on how you sign up for the Doggies in Town Service (e.g. through a third party service, via our website or a mobile provider), we share your first name or other User Data as necessary to enable your account. We may also share personal data with that third party about your use of the Doggies in Town Service, such as whether and to what extent you have used the offer, activated a Doggies in Town account, or actively used the Doggies in Town Service.
We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymised format.
Other Doggies in Town group companies
We will share your personal data with other Doggies in Town group companies to carry out our daily business operations and to enable us to maintain and provide the Doggies in Town Service to you.
Law enforcement and data protection authorities
We share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
Purchasers of our business
Social media sites
When you use our Services and elect to share information with third-party social media sites, the information you share will be governed by the privacy policies of those social media sites and the privacy settings you have set with those social media websites.
Third-parties may only collect or access information as needed to perform their permitted functions.
Certain Device operating system versions permit you to opt out of certain types of information sharing, including to certain advertising networks. Please check your Device settings if you want to limit such tracking.
We are committed to providing you with relevant content on our Services and respect the data privacy laws of the different jurisdictions which we operate in. We use information about you so we can help you enjoy and use our Services, including in the following ways:
- Register and manage your account, including to allow you access to and use of our Services
- Measure interest in and improve our Services
- Notify you about special offers and products or services available from us, our affiliates, or our partners that may be of interest to you
- Communicate with you
- Enable communication between registered users and owners/representatives of listings on our Services
- Enable us to publish your reviews, forum posts, photos, videos and other content
- Customize your experience, including customizing the ads shown to you on our Services and across the internet
- Make inferences about your interests or preferences
- Provide you with an optimized experience and to group users of our Services based on, for example, usage and demographics
- Send you survey or market research invitations
- Respond to your questions and comments
- Resolve disputes or troubleshoot problems
- Prevent potentially prohibited or unlawful activities
Please note some information about you is required in order for us to provide you with relevant offerings from us, our affiliates, and our partners and to enable you to enjoy other benefits of being a registered user. Please review the “Information Choices” section below with respect to your choices related to the collection and use of your information.
You have options with respect to the collection and use of your information. You can access, update and even close your account.
- You may choose the way we communicate with you. You can choose not to provide us with certain information, although it may be needed to take advantage of certain features offered on our websites.
- You can prevent the collection of geolocation information, but note that turning off location sharing may affect certain features of our Services.
- You also can add or update information and close your account. If you close your account, we will deactivate your account and remove your profile information from active view. We may retain some information associated with your account (including past transactions) for internal purposes including backups, fraud prevention, dispute resolution, investigations, and legal compliance for the period necessary to fulfill the purposes outlined in this Statement.
- As a registered member, you can modify your marketing subscriptions, including email subscription choices at any time. You also will be given the opportunity to unsubscribe from promotional messages, including emails.
We keep your personal data only as long as necessary to provide you with the Doggies in Town Service and for legitimate and essential business purposes, such as maintaining the performance of the Doggies in Town Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Doggies in Town Service. For example, we keep your account information and reviews.
If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:
- If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
- Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
- Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
We will destroy or delete your data in the event the data retention period has lapsed, you no longer maintain your account or if the purpose of data collection has been achieved.
The procedure and method of destruction and deletion is as follows:
- Procedure: Personal Information is disposed of, destroyed or deleted for the protection of information in accordance with our internal company policy and other applicable laws, after the purpose of its collection has been fulfilled.
- Method: Personal Information in paper format will be destroyed using paper shredder, and Personal Information stored in electronic format will be destroyed using technical methods which make the records unrecoverable.
Doggies in Town shares your personal data globally with Doggies in Town group companies in order to carry out the activities specified in this Policy. Doggies in Town may also subcontract processing to, or share your personal data with, third parties located in countries other than your country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country.
Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances Doggies in Town shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.
For further details of the security measures we use to protect your personal data, please see Section 12 ‘Keeping your personal data safe’ of this Policy.
We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Doggies in Town Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.
We are committed to protecting our users’ personal data. We only authorize specific employees to access personal information and they may do so only for permitted business functions.
We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.
Your password protects your user account, so we encourage you to use a strong password that is unique to your Doggies in Town account, never share your password with anyone, limit access to your computer and browser, and log out after having used the Doggies in Town Service.
The Doggies in Town Service is not directed to children under the age of 13 years. The Doggies in Town Service is also not offered to children whose age makes it illegal to process their personal data or requires parental consent for the processing of their personal data under the GDPR or other local law.
We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the Doggies in Town Service, and do not provide any personal data to us.
If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Doggies in Town, please contact us by sending an email to email@example.com, and you may request exercise of your applicable rights detailed in Section 3 ‘Your rights and your preferences: Giving you choice and control’ of this Policy.
If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the Doggies in Town account for that child.
We may occasionally make changes to this Policy.
When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Doggies in Town Service or by sending you an email and/or a device notification. We may notify you in advance.
Please, therefore, make sure you read any such notice carefully.
15.1 General Data Protection Regulation Privacy Statement (“GDPR Statement”)
This GDPR Statement applies to persons in the European Economic Area (“EEA”), including those based in the United Kingdom. This GDPR Statement supplements our Statement; however, where the Statement conflicts with the GDPR Statement, the GDPR Statement will prevail as to persons in the EEA.
15.2 Controller of Personal Information
Doggies in Town is the data controller of personal information we collect, however, in accordance with applicable data privacy law, we have appointed a representative within the European Union.
The contact details of our representative are:
Doggies in Town S.L.
Calle Pacifico 11,
29004, Málaga, Spain
Doggies in Town S.L. is the contact point for questions on data protection from European residents and data protection supervisory authorities.
15.3 Your rights under GDPR
You have certain rights regarding your personal data.
- Your rights with respect to your own personal data include the following:
- The right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
- The right to request to correct your personal data if it is inaccurate. You may also supplement any incomplete personal data we have, taking into account the purposes of the processing.
- The right to request deletion of your personal data if:
- your personal data is no longer necessary for the purposes for which we collected or processed them; or
- you withdraw your consent if the processing of your personal data is based on consent and no other legal ground exists; or
- you object to the processing of your personal data and we do not have an overriding legitimate ground for processing; or
- your personal data is unlawfully processed; or
- your personal data must be deleted for compliance with a legal obligation.
- The right to object to the processing of your personal data. We will comply with your request, unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.
- The right to restrict the processing of personal data, if:
- the accuracy of your personal data is contested by you, for the period in which we have to verify the accuracy of the personal data; or
- the processing is unlawful and you oppose the deletion of your personal data and request restriction; or
- we no longer need your personal data for the purposes of processing, but your personal data is required by you for legal claims; or
- you have objected to the processing, for the period in which we have to verify overriding legitimate grounds.
- The right to data portability. You may request that we send this personal data to a third-party, where feasible. You only have this right if it relates to personal data you have provided to us where the processing is based on consent or necessity for the performance of a contract between you and us, and the processing is conducted by automated means.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights described in this Statement). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In an effort to speed up our response, we may also contact you to ask you for further information in relation to your request. You can exercise several of your rights through the personal information section of your account. To exercise your other rights you can file a request by sending an email to firstname.lastname@example.org.
15.4 Information Uses
We will only use your personal data when the law allows us to.
Pursuant to GDPR, we will use your personal data in one or more of the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you
- Where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
- With your consent
15.5 International Transfers
Your personal data may be stored or transferred to countries outside the EEA for the purposes described in this Statement. When we store or transfer your personal data outside the EEA, we take the following precautions to ensure that your personal data is properly protected.
Whenever we store or transfer your personal data outside the EEA, we will do so in accordance with applicable law and we will ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. Transfers of personal data are made:
- to a country recognised by the European Commission as providing an adequate level of protection; or
- to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.
By using our services, you understand that your personal data may be transferred to our facilities and those third-parties with whom we share it as described in this Statement.
Thank you for reading our Policy. If you have any questions about this Policy, please contact us by sending an email to email@example.com or by writing to us at the following address:
Doggies in Town S.L.
Calle Panaderos 8
29005, Málaga, Spain
Doggies in Town S.L. is the data controller for the purposes of the personal data processed under this Policy.
We hope you enjoy Doggies in Town!